Alaska v. Wright

In 2009, an Alaska jury convicted Sean Wright of 13 counts of sexual abuse of a minor. After completing his Alaska sentence in 2016, Wright moved to Tennessee but failed to register as a sex offender as required by federal law. He pleaded guilty to failure to register and received a sentence of time served plus five years of supervised release. During those federal proceedings, Wright filed a habeas corpus petition in the U.S. District Court for the District of Alaska under 28 U.S.C. §§ 2241 and 2254, arguing that the Alaska Supreme Court had unreasonably applied federal law in rejecting his Sixth Amendment claims. The District Court dismissed for lack of jurisdiction because Wright was no longer "in custody pursuant to the judgment of a State court." The Ninth Circuit reversed, holding that Wright's state conviction was a "necessary predicate" to his federal conviction. The U.S. Supreme Court granted certiorari and unanimously reversed the Ninth Circuit on April 26, 2021.

The Supreme Court vacated the Ninth Circuit's judgment and remanded the case for further proceedings, holding 9-0 that Wright was not "in custody pursuant to the judgment of a State court" under § 2254(a) because his Alaska sentence had fully expired and his current custody stemmed from a federal conviction.

Whether a habeas petitioner is "in custody pursuant to the judgment of a State court" under 28 U.S.C. § 2254(a) when the state conviction is merely a necessary predicate to a subsequent federal conviction, but the state sentence has been fully served.

The decision reinforced the finality of state court judgments and closed a potential loophole that would have allowed individuals who had completed their state sentences to challenge those convictions through federal habeas corpus simply because the state conviction served as a predicate for a later federal offense. It clarified that federal courts lack subject-matter jurisdiction under § 2254(a) over petitions by persons no longer in state custody, regardless of collateral consequences such as sex offender registration requirements.